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that one year she gave her mother approximately $6,200 to assist
in paying her mortgage and electric bill; however, petitioners
could not recall the exact year of the donation or provide any
written substantiation for such a payment.
Section 151(c) allows for dependency exemption deductions in
certain circumstances. The father or mother of a taxpayer may
qualify as a dependent of the taxpayer if the taxpayer provides
over half of that individual’s support in the calendar year for
which the deduction is sought. Sec. 152(a)(4). Although
petitioners testified they provided support to Mrs. Booker’s
mother, their testimony was vague, and they did not establish a
definite amount for either year. In addition, petitioners
presented no written evidence to substantiate their
contributions. Mrs. Booker acknowledged that Ms. Mayfield
received at least $700 a month in unrelated support but failed to
establish the amount of support Ms. Mayfield received from all
sources during the years at issue. On this record, petitioners
failed to establish they contributed over half of Ms. Mayfield’s
support for each of the years in question. Respondent,
therefore, is sustained on this issue.
The next issue concerns itemized deductions claimed by
petitioners on Schedules A, Itemized Deductions, of their 1999
and 2000 income tax returns. Petitioners claimed substantial
deductions on their 1999 and 2000 returns under section 170 for
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